The $50 Million Bottleneck Inside the IRS CAF System

Bob Kerr returns to break down his Tax Notes article on the IRS's Centralized Authorization File, the decades-old system that processes Forms 2848 and 8821 almost entirely by hand, now buried under 7 million forms a year at roughly 500 staff years and $50 million to run. He, Roger, and Annie get into why the backlog keeps growing, how practitioners can get ahead of it by putting 8821s on file early, and why transcripts belong in your current-year filing, not just your representation work.

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https://www.taxnotes.com/tax-notes-federal/practice-and-procedure/high-costs-irss-centralized-authorization-file-system/2026/04/06/7vjcc

Chapters

(00:00) - Welcome and Setup

(02:36) - Why CAF Matters Now

(06:54) - CAF Explained POA vs TIA

(10:42) - Choosing 8821 vs 2848

(13:46) - Backlogs and Real Impacts